Memorandum by The Garden History Society
1. The Garden History Society is the national
amenity society for the study and protection of historic parks
and gardens. It is a statutory consultee on planning applications
affecting sites on the English Heritage Register of parks and
gardens of special historic interest. PPG 15 states that the
Society "has more experience of dealing with planning applications
affecting parks and gardens than any other body" (paragraph
REVISED PPG TO
2. This PPG offers the principal opportunity
to capitalise on the major re-evaluation of the importance of
public parks in the wake of the Select Committee report on town
and country parks (1999) and the Urban White Paper (UWP) (2000).
It is highly desirable therefore that the PPG specifically addresses
the contribution parks make to the quality of life, to local distinctiveness
and to the aims of sustainability.
3. That contribution is different from other
forms of open space and from other forms of recreation facility.
It is essential that the PPG sets out and employs a reasoned terminology
and typology in dealing with what may be related but are in fact
fundamentally different resources.
4. It is unfortunate that the PPG emerged
just as the Government's Urban Parks and Green Space Taskforce
began its work. We believe that it would be preferable to wait
for the Taskforce to report and incorporate its findings in the
PPG than to rush out what at present is a fatally flawed document.
If the Government is determined to rush ahead with publication,
we strongly advise that an interim Annex on parks be prepared
for the PPG, flagging up the emergence of further Government advice
on parks in the wake of the Taskforce report.
5. Turning to specific faults in the draft,
which affect its ability to deliver on strategic planning for
sport, open space and recreation, there is a fundamental flaw
in the document's erratic terminology and lack of definitions.
For example in paragraph three, the second sentence refers to
"sports facilities, parks and open . . . spaces", but
by the end of the paragraph the subject of the paragraph has changed
to "sport and recreation facilities".
6. The phrase "recreation facilities"
is never defined and as a result confuses facilities comprising
buildings, with facilities comprising open space.
7. "Open space" needs to be unpacked
and its various aspects carefully defined. It currently appears
to include a vast range of spaces which, although sharing the
basic test of being of "public value", have entirely
different management and planning requirements. It appears to
include such differing types as nature reserves, hard-paved town
squares, amenity grassland, playing fields, canal sides, skate
parks, kickabout surfaces, urban parks and public gardens, and
8. "Recreation" also needs to
be broken down, and carefully defined. Since the original PPG
17 which signally failed to address other forms of open space
enjoyment, "recreation", is widely inferred to mean
sport. In paragraph two we are told that the government objectives
relevant to this PPG are only those for "sport and recreation",
omitting open space. "Recreation" must be defined as
clearly encompassing both formal recreation (ie formal sport,
and possibly formal play using equipment and defined play areas),
informal recreation (informal sport and play, walking) and passive
recreation (sitting, chatting, bird-feeding, admiring flowers,
9. The phrase "informal open space"
is introduced at paragraph 14, but nowhere is it defined, or distinguished
from "formal" open space: no one can guess what it means.
We are genuinely unclear what this means: kickabout areas, marginal
land, public parks? We believe that a rigorous terminology is
absolutely essential in a PPG. Urban parks, botanical gardens,
country parks and cemeteries for example are "formal open
space" in the physical sense: intensive horticulture and
design, built structures, path networks, designated areas for
different activities, and by-laws; but possibly "informal"
in the uses they accommodate.
10. We also believe that a category should
be identified to cover hard landscape such as urban plazas and
piazzas; this could be termed "grey space", or "civic
space" for example.
11. The draft PPG fails to provide sufficient
clarity because it does not identify the special importance of
parks as distinct from other kinds of "recreational facility".
The contribution of public parks and gardens is qualitatively
different from, and affects a far greater proportion of the population
than, that made by sports facilities. Indeed the two can often
be in conflict: sports development can detract from the cherished
qualities of an urban park, by physically developing part of the
park, and by eroding the tranquility which is often a park's most
valued characteristic. It is absolutely essential therefore that
the flawed conflation of the two, running throughout this draft,
12. The PPG not only needs to sort out definitions
internally, but it needs to make definition of open space the
subject of its guidance to local authorities, and it needs to
ensure that such definitions are made to nationally consistent
standardsthe PPG is the best place to set out such definitions
and standards (see 18 below).
13. The PPG should be the ideal vehicle
for government to express its strong advice that every local planning
authority should produce "parks and open spaces strategy".
Such a strategy needs to be based on a consistent typology, good
data and needs-assessment.
14. The PPG does not recognise what the
Select Committee and the DTLR Taskforce refer to as "the
information deficit" when it comes to parkstheir numbers,
their condition, their funding, their use and the wishes of the
local community. This must be flagged up, and the collection and
analysis of reliable data must be a priority for planning authorities.
PPG TO PROVISION
15. Needs-assessment appears to be heavily
skewed towards sports provision: Sport England, referred to in
paragraph 17, does not address needs assessment for passive recreation
and informal play, let alone for the other benefits of well-designed
parks and gardens, except for the narrow band of sports-users.
We welcome paragraph 22 on assessing informal recreational facilities
(here facilities seems to mean open space as well as buildings)
but it is isolated in a section (paragraphs 17-23) dominated by
the well-established methodologies for assessing sports and playing
fields provision. The PPG needs at least to outline a methodology
for needs-assessment and evaluation for passive recreation of
the kind enjoyed by park-users.
16. The desirability of providing good,
well-designed new parks and open spaces is flagged up in PPG 3,
and in the Urban White Paper. The most practical mechanism for
this is afforded by planning obligations and s. 106 agreements.
It is essential that there is an end to tokenismfragmented
or soul-less areas of mown grass which makes no contribution to
amenity, wildlife, or landscape. The PPG should emphasise the
message in PPG 3 that agreements must emphasise quality over quantity,
and alsoas wisely pointed out in paragraph 62ensure
resources for proper maintenance. Paragraph 56 refers to By
Design, but that does not give examples of good designs for
parks, gardens and open spaces, only for features within them.
17. We would also urge the inquiry to consider
that provision of new open space is less of an issue than the
good management of existing. Advice on this subject is woefully
lacking in the draft PPG, and while management may be the responsibility
of a separate local authority department from planning, it is
essential that planners understand management issues; for example,
in drafting s. 106 agreements that secure new open space, orin
the wider sensein delivering the kind of green space which
will contribute to the planning objectives of the urban renaissance.
18. Despite its familiarity to planners,
the NPFA six-Acre standard has proved to be an inadequate mechanism
for delivering quality open space: it is essentially a
quantative measure. While the PPG acknowledges the need
for quality, it does not tackle the future provision of national
standards. We believe that this is a serious omission.
THE PPG IS
19. From the above, it should be clear that
we think the PPG is largely unsuccessful in this. The subject
of open space appears to have been "bolted on" to the
existing sport and recreation guidance. It is neither afforded
enough guidance in its own right nor explored in relation to sport
20. We believe that as it stands, the PPG
would not only fail to give strategic guidance on open space;
it would have a negative impact as a result of its confused wording.
PPG TO ACHIEVING
21. We have been anticipating this draft
with great interest in the light of the Urban White Paper. That
document promised that the revised PPG would "give local
planning authorities a clearer framework for assessing their needs
for open spaces, making good deficiencies and protecting what
is valued, and ensuring that everyone has adequate access to open
space". The PPG would also, the White Paper went on, "aim
to ensure that existing spaces are protected from development
where appropriate and that new open spaces are well designed".
In the light of these expectations, we must express our disappointment
at the draft, and urge that significant changes are needed if
it is (a) to deliver what the UWP promised and (b) not to have
a negative impact on strategic planning for open space.
22. The PPG does not contribute to the aspirations
set out in the UWP. Those aspirations are being worked through
and developed by the Urban Parks and Green Space Taskforce set
up in the wake of the publication of the Urban White Paper, and
it makes little sense to publish a document purporting to join
up with the Urban White Paper in advance of the Taskforce report.
The evidently hurried nature of the PPGs treatment of open space
suggests that it is intended to fulfil the promises in the UWP,
but it patently fails to do so.
23. In conclusion, we are uncertain whether
to advise that the PPG needs fundamental revisions, or that open
space merits its own separate PPG. This will clearly be a matter
for the Committee, but on balance, we would favour the former
option. Securing an entirely new PPG would we guess be a lengthy
matter. However, the flaws in the existing draft should not be
underestimated and if the eventual version of the PPG is to be
useful, then serious work is needed. We would certainly advise
that the DTLR Taskforce report be used to inform the drafting,
and in particular we must highlight the need for:
a proper terminology and typology;
guidance on national standards;
guidance on strategic planning for
guidance on understanding management.